G.R. No. 104 : April 22, 1902
THE UNITED STATES, complainant-appellee, vs. ALEJANDRO VALDEZ, defendant-appellant.

FACTS:
Alejandro Valdez was convicted by the Court of First Instance as the principal in the crime of homicide for the killing of Martin Evangelista. He was sentenced to fourteen years, eight months, and one day of reclusion temporal, with accessories, ordered to indemnify the heirs of the deceased in the amount of 700 pesos, and to pay a portion of the costs. His co-defendants were acquitted. Valdez appealed the judgment. In his testimony, Valdez claimed that the victim was killed by another person, Venancio Cariaga, while the victim was bound elbow to elbow.

ISSUE:
Whether the trial court correctly classified the crime as homicide and properly convicted the appellant based on the evidence.

RULING:
The Supreme Court affirmed the judgment of the lower court. The guilt of Alejandro Valdez was fully proven. The Court held that the evidence was insufficient to establish any of the qualifying circumstances under Article 403 of the Penal Code that would elevate the crime to murder. Specifically, the Court rejected Valdez’s testimony that the victim was bound and killed by another, finding it entirely unreliable. The Court reasoned that this testimony was given solely to incriminate another person and exculpate himself, with evident disregard for the truth, and therefore could not be considered a confession. Such testimony could only be accepted if corroborated by other evidence, which was absent. Consequently, the crime was properly classified as homicide, and the penalty imposed was correct. The appealed judgment was affirmed, with costs against the appellant.